Towards a New London Plan consultation response
Shaping a greener, fairer London: our response to the Towards a New London Plan consultation
The New London Plan is now open to public consultation, inviting feedback on how we can better shape the city’s development for Londoners in the years ahead.
Love Design Studio along with our sister company Shade the UK, have published a set of recommendations in response to the ongoing Towards a New London Plan public consultation. Our focus is on key environmental and social issues including overheating, air quality, pollution, circular economy strategies and nature-based solutions.
These are areas where we think design can meaningfully contribute to London’s future to help shape a healthier, more resilient city for all.
Have a read through our responses below and share your own thoughts on the plan by Sunday 22 June, 11:59 pm BST.
Andy Love
Managing Director, Love Design Studio
It’s been a real privilege to contribute to early-stage thinking around the new London Plan at City Hall. I hope that Love Design Studio continues to be a valuable peer to the Greater London Authority (GLA), offering honest, practical insights that helps shape a plan grounded in people, place, and purpose.
London’s greatest asset will always be its people, but close behind that is the incredible character of the city itself. The hidden streets and mews you stumble across by accident. The vibrant patchwork of neighbourhoods, each with their own feel and flavour. The layers of history embedded in its buildings and parks. Our culture of tolerance, ambition, and defiance. Our nightlife, our fashion, our humour. Our ability to live side by side with difference, and our constant reinvention of what a global city can look like.
I worry that over the last decade, major development in London has stopped breaking boundaries. While we rightly steer clear of unnecessary vanity projects, it’s hard to name a landmark development since the Olympic Park that has captured the imagination, let alone shaped a new identity. Residential design in particular has lost its edge. We’re seeing too much templated, risk-averse development that strips the city of its texture.
As we move into the latter half of this decade, we have an opportunity, and an obligation, to bring design excellence back to the forefront. The planning system must reward brave, human-centred, and culturally rich design. Not just what ticks a box, but what stirs pride and excitement.
Let’s move away from a monoculture of building design and embrace the eclecticism that makes London thrive. Let’s support organic community growth, working with people rather than designing at them. And most importantly, let’s put adaptation at the heart of planning. Adaptation, adaptation, adaptation. We cannot afford to be trapped in a carbon tunnel vision that overlooks biodiversity, wellbeing, or social resilience.
At Love Design Studio, I’m proud of the depth of our understanding across the environmental and social themes within the Plan, from overheating and retrofit to circular economy, air quality, and nature-based solutions. Our team cares deeply about this city and the role design plays in shaping it. I’m proud to share their thoughts below.
Polly Turton
Head of Climate Action and Public Health, Shade the UK
Section 4 – London’s Capacity for Growth and Design Quality
Paragraph 4.6: Heat risk, ventilation and overheating
My main idea is to establish an outdoor, simplified version of the existing Cooling Hierarchy (4.6) called something along the lines of the ‘thermal comfort design hierarchy’. This would apply to all public realm improvement projects in London, as well as any new amenity space created as a result of new developments. This would strongly support the Healthy Streets principles (5.13).
In addition to the vital objectives of increasing green space and tree cover (5.5), I would also introduce ‘tactical shade structures’ in outdoors areas of high heat risk exposure* (5.14) particularly where new tree planting may not be possible or where shade is needed sooner than new trees can grow. This would greatly support public essential health policies (5.19). These ‘tactical shade structures’ could potentially complement the locations of existing and planned GLA drinking water refill stations and/or designated cool spaces.
*High heat risks areas include outdoor areas exposed to heat, where vulnerable groups of people live, work, move through, spend time, where heat sensitive assets are located and where heat sensitive activities take place.
Figure 1: Hierarchy of thermal comfort for external public spaces
© Shade the UK
Tony Truepenny-Phillipson
Senior Sustainability Consultant, Energy & Retrofit
Section 5 – London’s Infrastructure, climate change and resilience Paragraph 5.2: Heat Networks
I would like to see more detail on how proposals for decarbonisation of existing communal and district heat networks would be implemented. Many apartment buildings throughout London rely on communal or district heat networks that are gas-powered. Replacing these with low-carbon alternatives will be expensive, and the transformation must be carefully planned. Any proposals for changes to existing systems and installation of new low-carbon heat networks should also give consideration to the heat rate costs charged to residents, which are often extortionate, and how this will affect fuel poverty across London.
Paragraph 5.1: Heat risk
I would like the new London Plan to include clearer guidance and policies on the retrofit and installation of passive design measures for both new and existing buildings to help reduce overheating risk in homes. Promoting featured such as external shading and shutters would hopefully trickle down into the London borough's local policies over time and lead to an increase in the adoption of these measures to promote effective cooling strategies over time.
Sophia Major
Senior Sustainability Consultant, Zero Waste
Paragraph 5.3: Whole life-cycle carbon (WLC) and Circular Economy (CE)
I would like to see the London Plan place greater emphasis on embedding circular economy principles in design decision-making, particularly around building retention and material reuse. While the current Circular Economy Statement (CES) guidance offers a clear framework for assessing when demolition versus retention is appropriate, the real challenge often lies in how those justifications are applied and interpreted. Retention is rightly favoured, but it is not always feasible. Therefore, greater emphasis should be placed on ensuring transparency and consistency in how these decisions are evaluated. For example, while structural assessments are sometimes used to justify demolition over retention, cost is also frequently cited as a determining factor with limited clarity on how those judgments are made or evaluated. A standardised matrix could help formalise this decision-making process by setting out measurable criteria for when retention should be prioritised and when demolition may be justified. This would not replace professional judgment but would provide a clearer, more transparent and consistent basis for decision-making across boroughs.
The inclusion of Whole Life-cycle Carbon benchmarks in the current plan is a positive step, but CES policies and targets remain relatively weak by comparison. Many CES submissions make ambitious claims that often meet the 95% landfill diversion rate without clear performance targets or post-construction validation. Currently, there is little follow-up to ensure circular economy principles are delivered in practice. Introducing clearer expectations, such as minimum reuse rates, recycled content targets with post-completion reporting, would help move CESs from theory to meaningful delivery.
On a practical level, more support is needed to enable circular economy delivery on real projects. I support the focus on enabling premises for reuse, upcycling, and materials processing as this type of infrastructure is key to helping deliver circular economy in practice. However, I would also suggest encouraging more incentives, such as business rates reliefs and subsidies for projects that can meet strong reuse or recovery targets.
Connor Rusby
Senior Sustainability Consultant, Air Quality
Paragraph 5.14: Car parking, cycle parking and deliveries
Whilst this section touches on it, I think it is critical that the outskirts and suburban regions of London are not left behind. Outer areas like Sutton and Bexley are still extremely car dependant and reflect a legacy of London’s past and outdated urban planning. New developments in these areas are still being built with high levels of parking provision, which is often justified by poor public transport connectivity. This only reinforces car dependency, especially in areas where there is also a lack of safe, usable cycling infrastructure.
Strengthening the link between housing and transport is critical, but local authorities must be on board for a car-free future. Parking and car use is divisive and political in a lot of outer regions of London, so local authorities need to feel empowered by the long-term vision of lowering car use.
Clean air should continue to be used as a motivating driver for reducing car use. However, changing the language and thinking away from exhaust fumes to brake and tyre wear will be required to keep momentum on lowering car use as the national fleet shifts to EV.
Paragraph 5.7: Green infrastructure and biodiversity
A more integrated approach is needed when it comes to Urban Greening Factor (UGF) and Biodiversity Net Gain (BNG). We often see different consultants developing these inherently connected reports which can lead to disparities in findings and information presented.
The UGF also needs refinement when applied to smaller sites that may encompass a larger red line (for example a small apartment building that includes an access road and bin store in the red line). Often larger red lines encompass areas where greening is not possible (roads, walkways, pedestrian crossings) meaning the UGF cannot be met despite considerable greening efforts. Nuance is needed on how this is considered to maximise the opportunities around UGF, there is a risk that developments simply see this is an impossible ask and then do not put effort in meeting it.
Paragraph 5.17: Air Quality
The call for response 5.17: Air Quality references the WHO guidelines, but these need to be considered in local decision making if London wants to keep momentum in tackling air pollution. There are boroughs that are working to implement these targets as part of local plans, but I believe there is not enough oversight and guidance on how this is done. If these more stringent guidelines are to come in, there needs to be a mitigation hierarchy that is dependent on pollutant levels across the site. We need to move away from the more objective yes/no to understand if a development meets the thresholds, which can sometimes lead to drastic measures like sealed windows which in turn contribute to overheating and other health risks.
The Air Quality Positive (AQ) policy is a positive step but is not far-reaching enough. Limiting its application to only EIA-scale developments excludes over 90+% of planning applications, which means that the majority of new developments are not required to demonstrate a positive contribution to air quality. And if they are, this isn't celebrated or accounted for. Establishing benchmarks - similar to the whole life carbon approach - could be an effective tool to assess ‘AQ positivity’, potentially mandating developers to consider a matrix of interventions and then calculate the improvements associated with each. New housing above high streets, shops and urban centres will rarely meet the requirements for an AQ positive approach and yet will experience the highest concentrations of pollutants in London.
There needs to be a shift in language and focus from NO₂ and combustion emissions to PM2.5 and non-exhaust emissions. The focus on construction is welcomed and could be modelled as part of a 'whole life air quality' approach to emissions. Similarly, we often focus on local emissions but with PM2.5 being a key focus area moving forward there could be an expansion to air quality assessments across the lifecycle of materials and components. Steel production is one of the leading sources of pollutant emissions and this is not considered in AQ assessments as it released away from developments, how does this align with the new PM2.5 target that is focussed on exposure?
More generally the current air quality assessment methodologies in the UK are no longer fit for purpose. The vast majority of developments can either be ruled out from detailed analysis, or are deemed to have no significant impact associated with the development. The London Plan could explore and reinvent the established approaches to air quality assessments. There are AI companies producing air quality reports instaneously which is indicative of the need for a better methodology and approach to assessment.
Specific guidance is urgently needed on how the new PM2.5 targets will be implemented within planning policy, and how consultants and developers are expected to respond.
Paragraph 5.18: Heat Risk
Overheating is a major issue across all urban centres, but especially in London given the UHI effect, high population density and noise-related constraints. Part O introduces stringent requirements associated with acoustic levels that make it extremely difficult to rely on openable windows in the summer, given the noisy nature of the capital, which in turn leads to an overreliance on active cooling. The London Plan should consider the production of a specific approach to overheating that balances the amenity of users and the risk of health impacts. Similarly, there is not enough emphasis on designing for future climate scenarios; the new London plan must mandate consideration and statistical testing of future climate scenarios to account for overheating risk for the full lifecycle of building.
New builds are particularly vulnerable to overheating given the insulation and fabric requirements of Part L. The London Plan could be more forward thinking in allowing major shading structures and novel approaches to cooling buildings. Overheating is also an issue in older buildings, and a passive approach to cooling (shading/shutters/window changes) is often limited by heritage and conservation concerns. A sensible middle ground needs to be met that balances the retention of beautiful historical buildings with the real risk they will simply not be usable in future summers.
With respect to outdoor spaces, there needs to be of a monitoring network of key outdoor areas that will allow the GLA, consultants, and the public access to temperature data in key outdoor areas. Microclimate will dictate an individual's experience in a region far more than the temperatures reported on weather apps and websites. This could be used to inform design decisions and user decisions during hot spells.